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Numbers a charity prints in its donor letters are indexed, and the IRS republishes them every year. Two figures in the statute are not. Under 26 U.S.C. 170(f)(8)(A), no deduction is allowed for a contribution of $250 or more without substantiation.¹ What substantiates it is "a contemporaneous written acknowledgment of the contribution by the donee organization that meets the requirements of subparagraph (B)."¹ Under 26 U.S.C. 6115(a), an organization described in section 170(c) that receives a quid pro quo contribution "in excess of $75" has to provide a written statement.² Neither the $250 nor the $75 carries an inflation adjustment.

What the acknowledgment has to say

Subparagraph (B) sets out three items. The first is "The amount of cash and a description (but not value) of any property other than cash contributed."¹ The second is "Whether the donee organization provided any goods or services in consideration, in whole or in part, for any property described in clause (i)."¹ The third is a description and good faith estimate of the value of those goods or services, or, where they "consist solely of intangible religious benefits, a statement to that effect."¹

Subparagraph (C) measures the deadline from the donor's side rather than the charity's. An acknowledgment is contemporaneous where "the taxpayer obtains the acknowledgment" on or before the earlier of two dates.¹ The first is the date the taxpayer files a return for the year of the contribution, and the second is "the due date (including extensions) for filing such return."¹ What the letter is dated is not what the subparagraph measures.

The thresholds are set outside the regulation

Treasury's rule names other documents. Under 26 CFR 1.170A-13(f)(8)(i)(A), goods or services are disregarded where they have "insubstantial value under the guidelines provided in Revenue Procedures 90-12, 1990-1 C.B. 471, 92-49, 1992-1 C.B. 987, and any successor documents."³ Rev. Proc. 90-12 sets a precondition and then two alternatives.⁴ The precondition is that the payment occur in a fund-raising campaign in which the charity tells patrons how much of the payment is deductible.⁴ The first alternative is that the fair market value of the benefits "is not more than 2 percent of the payment, or $50, whichever is less".⁴ The second is that the payment is $25 or more and the only benefits are token items bearing the organization's name or logo.⁴

One figure, three documents, three years

Those base amounts are indexed, and the successor documents come out annually. Publication 1771, the guide written for charities, was last revised in November 2023, and it footnotes its own numbers: "The dollar amounts are for 2023. Guideline amounts are adjusted for inflation."⁵ Its three figures are $125, $62.50, and $12.50.⁵ Rev. Proc. 2024-40, at section 2.34, gives $136.00, $68.00, and $13.60 for taxable years beginning in 2025.⁶ Rev. Proc. 2025-32, at section 4.33, gives $139, $69.50, and $13.90 for 2026, and states that these are the $50, $25, and $5 guidelines of Rev. Proc. 90-12 "respectively."⁷

The publication says which year its figures belong to. The footnote sits under a table, and a number copied out of a table is copied without it. A template assembled that way carries the 2023 amounts into a letter written for a later year.

The penalty attaches to a contribution

Section 6714(a) sets the amount. An organization that does not meet the disclosure requirement of section 6115 "shall pay a penalty of $10 for each contribution in respect of which the organization fails to make the required disclosure."⁸ The same subsection caps the total, so that it "shall not exceed $5,000" for "a particular fundraising event or mailing."⁸ Subsection (b) provides that no penalty is imposed "if it is shown that such failure is due to reasonable cause."⁸ The contribution is what the $10 attaches to, and the mailing is only what the cap is measured against.

Where the editing stops

An organization's finance staff and its own tax advisors decide what a benefit is worth, whether a payment is a quid pro quo contribution, and which year's figures apply to a letter. None of that is an editorial question. We answer none of it, and we do not check the arithmetic behind a figure.

A client's writing is confidential and stays that way. Reading a template against the revenue procedure a client names will show whether the printed figure matches that procedure. Whether a letter carries the sentence about goods and services is a question about the page, and the answer does not depend on the organization's tax position. Where a description of property also carries a value, the statute asks for the description and not the value, and that shows on the page without anyone knowing what the property is worth.

An acknowledgment is drafted once and sent to many donors, often by staff who did not write it. A correction made to the template afterward does not reach the letters already mailed. The figures inside those letters were fixed earlier still.